CALIFORNIA PRIVACY POLICY

Opinionsltd.com

This Privacy Policy for California residents supplements the information contained in the Privacy Policy of Opinions, Ltd. and its subsidiaries and affiliates (“Opinions,” “we,” “us”), and it applies solely to visitors, users, and consumers residing in the State of California (“consumers” or “you”). Opinions has adopted this Policy for compliance with the California Consumer Privacy Act of 2018 (the “CCPA”) and other California privacy laws. Terms used here have the same meanings given to them by the CCPA.

Information We Collect

Opinions collects information that identifies, relates to, describes, references, can be associated with, or could reasonably be linked (directly or indirectly) with a particular consumer or device (“personal information”). Personal information does not include:

• Publicly available information obtainable from government records.
• De-identified or aggregated consumer information.
• Information excluded from the CCPA, such as:
o Health or medical information covered by the Health Insurance Portability and Accountability Act of 1996,
and the California Confidentiality of Medical Information Act, or clinical trial data;
o Personal information covered by certain sector-specific privacy laws, such as the Fair Credit Reporting Act,
the Gramm-Leach-Bliley Act, the California Financial Information Privacy Act, or the Driver’s Privacy
Protection Act of 1994.

The following summarizes the personal information that we may have collected within the past twelve (12) months:

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A. Identifiers

Yes, We Collected

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B. Personal Information categories listed at Cal. Civ. Code § 1798.80(e) (California Consumer Records statute)

Yes, We Collected

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C. Classifications protected by California or Federal Law

Yes, We Collected

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D. Commercial Information

Yes, We Collected

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E. Biometric Information

Yes, We Collected

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F. Network or Other Similar Internet Activity

Yes, We Collect

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G. Geolocation Data

Yes, We Collect

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H. Sensory Data

Yes, We Collect

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I. Professional or Employment-Related Information

Yes, We Collect

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J. Non-Public Education Information (Family Educational Rights and Privacy Act, 20 U.S.C. § 1232(g), 34 CFR 99)

Yes, We Collect

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K. Inferences drawn from other personal information

Yes, We Collect

We obtain the above-listed categories of personal information from the following categories of sources:

• Directly from our clients or their agents. For example, from documents that our clients provide to us related to the services that we provide.
• Indirectly from our clients or their agents. For example, through information we collect from our clients while we provide services to them.
• Directly and indirectly from activity on our website (www.opinionsltd.com). For example, from submissions through our website portal or website usage details collected automatically.
• From third-parties that interact with us in connection with our services. For example, from clients who ask us to perform market research surveys.

Use of Personal Information

We may use, sell or disclose the personal information we collect for one or more of the following business purposes:

• To fulfill or meet the reason for which the information is provided. For example, if you share your name and contact information with us to request a price quote or ask a question about our services, we will use that personal information to respond to your inquiry.
• To provide you with information, products or services that you request from us.
• To provide you with email alerts, event registrations, or other notices concerning our products or services, including events or news that may be of interest to you.
• To carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collections.
• To improve our website and present its contents to you.
• For testing, research, analysis and product development.
• As necessary or appropriate to protect the rights, property or safety of us, our clients or others.
• To respond to law enforcement requests or otherwise as may be required by applicable law, rule, regulation, or court order.
• As described to you when collecting your personal information or as otherwise set forth under the CCPA.
• To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by us is among the assets transferred.

We will not collect additional categories of personal information or use the personal information we collected for materially different, unrelated, or incompatible purposes without notifying you.

Sharing of Personal Information

We may disclose your personal information to third parties for business purposes, or to sell your personal information, subject to your right to opt-out of those sales. When we disclose personal information for business purposes, we enter into a contract that describes the purposes of the disclosure and requires the recipient to both keep that personal information confidential and not use it for any purposes other than those required to perform the contract.

In the preceding twelve (12) months, we have disclosed the following categories of personal information for business purposes:

• Category A: Identifiers.
• Category B: California Customer Records personal information categories.
• Category C: Protected classification characteristics under California or federal law.
• Category D: Commercial information.
• Category E: Biometric information.
• Category F: Internet or other similar network activity.
• Category G: Geolocation data.
• Category H: Sensory data.
• Category I: Professional or employment-related information.
• Category J: Non-public education information.

We disclose your personal information for business purposes to the following categories of third parties:

• Our clients.
• Our affiliates.
• Service providers.
• Third parties to whom you or your agents authorize us to disclose your personal information in connection with the services that we provide.

In the preceding twelve (12) months, Opinions has not sold personal information.

Your Rights and Choices

The CCPA provides consumers (California residents) with specific rights regarding their personal information. This section describes those rights and explains how you can exercise them.

Access to Specific Information and Data Portability Rights

You have the right to ask us to disclose certain information to you about our collection and use of your personal information over the past twelve (12) months. Once we receive and confirm your verifiable consumer request, we will disclose to you:

• The categories of Personal information that we collected about you.
• The categories of sources for the Personal information that we collected about you.
• Our business or commercial purposes for collecting or selling that Personal information.
• The categories of third parties with whom we shared that Personal information.
• The specific pieces of Personal information we collected about you (also called a data portability request).
• If we sold or disclosed your Personal information for a business purpose, we will provide you with two separate lists disclosing:
o sales, identifying the Personal information categories that each category of recipient purchased; and
o disclosures for a business purpose, identifying the personal information categories that each category of
recipient obtained.

Deletion Request Rights

You have the right to request that we delete any of your personal information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request, we will delete (and direct our service providers to delete) your personal information from our records, unless an exception applies.

We may deny your deletion request if retaining the information is necessary for us or our service providers to:

• Complete the transaction for which we collected the personal information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you.
• Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
• Debug products to identify and repair errors that impair existing intended functionality.
• Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
• Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 seq.).
• Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws (when the deletion of the information is likely to render impossible or seriously impair the research, if you previously provided informed consent).
• Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
• Comply with a legal obligation.
• Make other internal and lawful uses of that information that are compatible with the context in which you provided it.

Exercising Your Access, Data Portability, and Deletion Rights

To exercise the access, data portability, and deletion rights described above, please submit a verifiable consumer request to us via the link on our website, mail, phone, or email:

Opinions, Ltd.
31 South Franklin Street
Chagrin Falls, Ohio 44022
United States
Tel.: +1 (877) 595-0993
Email: CCPA@opinionsltd.com

Only you or a person registered with the California Secretary of State that you authorize to act on your behalf may make a verifiable consumer request related to your personal information.

You may also make a verifiable consumer request on behalf of your minor child. You may only make a verifiable consumer request for access or data portability twice within a 12-month period. Your request must:

• Provide sufficient information that allows us to reasonably verify that you are the person (or that person’s authorized representative) about whom we collected personal information.
• Describe your request with details sufficient for us to properly understand, evaluate, and respond to it.

We cannot respond to your request if we cannot verify your identity, confirm that you are authorized to make the request, and/or confirm that personal information requested actually relates to you. Making a verifiable consumer request does not require you to create an account with us. However, we may consider requests made through your password protected account with us sufficiently verified when the request relates to personal information associated with that specific user account. We will only use personal information provided for purposes of submitting a consumer request to verify the requestor’s identity or authorization to make the request.

Response Timing and Format

We endeavor to confirm receipt of all consumer requests within ten (10) business days of receipt. Thereafter, we endeavor to respond to all verifiable consumer requests within 45 days of receipt. If we require more time (up to 90 days), we will inform you of the reason and extension period in writing. If you have an account with us, we will deliver our written response to that account. If you do not have an account with us, we will deliver our written response by mail or email, at your option. Any disclosures we provide will only cover the 12-month period preceding our receipt of your verifiable request. The response we provide will also explain the reasons that we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your personal information that is readily usable and should allow you to transmit the information from one entity to another entity without hindrance, specifically, via email. We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.

Personal Information Sales Opt-Out and Opt-In Rights

If you are 16 years of age or older, you have the right to direct us not to sell your personal information at any time (the “right to opt-out”). We do not sell the personal information of consumers we actually know are less than 16 years of age, unless we receive affirmative authorization (the “right to opt-in”) from either the consumer who is at least 13 but not yet 16 years of age, or the parent or guardian of a consumer less than 13 years of age. Consumers who opt-in to personal information sales may opt-out of future sales at any time.

To exercise the right to opt-out, you (or your authorized representative) may submit a request to us by visiting the following webpage: Do Not Sell My Personal Information

Once you make an opt-out request, we will wait at least twelve (12) months before asking you to reauthorize personal information sales. You may, however, change your mind and opt back in to personal information sales at any time by following the instructions available here: I Would Like to Opt-In

You do not need to create an account with us to exercise your opt-out rights. We will only use personal information provided in an opt-out request to review and comply with the request.

Non-Discrimination

We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:

• Deny you goods or services.
• Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
• Provide you a different level or quality of goods or services.
• Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.

We may offer market research survey respondents certain financial incentives permitted by the CCPA in exchange for their participation in our market research projects. Incentives differ between different market research projects. Survey respondents’ participation in a given project requires their prior opt-in consent, which they may revoke at any time. Survey respondents’ voluntary participation in our research projects is based on their desire to share their opinions. In addition to providing respondents with opportunities to share their opinions, and to thank them for their participation, respondents may receive a check, a gift card or cash. The value of respondents’ survey responses is determined by the objectives and complexity of the particular research project that their responses will support. Project research objectives are determined by our clients’ needs, which are influenced by a variety of factors. These factors include:

(1) The budget for a particular market research project. Our clients’ needs and the objectives and complexity of a research project determine the project’s budget.

(2) The objectives of the research. Our clients’ needs also determine this factor. The purpose of market research is generally to collect feedback from a target audience to understand their characteristics, expectations and inclinations. Different projects have different objectives.

(3) Statistical significance. Statistically significant survey results help our clients by providing them with insights into consumers’ characteristics, expectations and preferences. The objective of a particular study determines the number of survey respondents needed to test for statistical significance; in turn, the number of respondents needed impacts how much of a project’s budget is allocated to permitted financial incentives.

(4) The length of time that completing a survey is estimated to take. These estimates are based on the number and complexity of the survey questions, as well as our past experience conducting market research surveys of all kinds.

(5) The study incidence rate. This factor refers to how easy or difficult it is to find the target population of survey respondents. The incidence rate is calculated by dividing the number of qualified respondents by the total number of respondents who were screened for the study.

(6) Project feasibility. This overarching factor determines project timing and cost by accounting for the study methodology, when and for how long the study is being conducted, who the respondents are, and how many respondents are needed.

By signing up to participate in in one of our surveys, respondents agree to let us collect personal information from them for the purpose of facilitating their participation. Survey respondents’ participation is entirely optional, and they can withdraw from participating at any time by contacting us at:

Opinions, Ltd.
31 South Franklin Street
Chagrin Falls, Ohio 44022
United States
Tel.: +1 (877) 595-0993
Email: CCPA@opinionsltd.com

Other California Privacy Rights

California’s “Shine the Light” law, Cal. Civ. Code § 1798.83, permits users of our website that are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please email us at: ccpa@opinionsltd.com

Changes to Our Privacy Notice

We reserve the right to amend this privacy notice at our discretion and at any time. When we make changes to this privacy notice, we will notify you by email or through a notice on our website homepage.

Contact Information

If you have any questions or comments about our Privacy Policy, the ways in which we collect and use your personal information, your choices and rights regarding such use, or if you wish to exercise your rights under California law, please do not hesitate to contact us at:

Opinions, Ltd.
31 South Franklin Street
Chagrin Falls, Ohio 44022
United States
Tel.: +1 (877) 595-0993
Email: CCPA@opinionsltd.com

Submit Requests (California Residents Only)

Access Requests (do one of the following)
Click here
Email us at CCPA@opinionsltd.com
Call (877) 595-0993

Deletion Requests (do one of the following)
Click here
Email us at CCPA@opinionsltd.com
Call (877) 595-0993

Do Not Sell My Information Requests (do one of the following)
Click here
Email us at CCPA@opinionsltd.com
Call (877) 595-0993